Case Summary (G.R. No. 1434)
Key Dates
- August 30, 1902: De los Reyes purportedly received a captain’s commission in the insurgent army.
- November 21, 1902: He was arrested in Manila and a revolver and sealed commission were seized.
- February 23, 1904: Decision rendered by the Supreme Court of the Philippine Islands.
Applicable Law
- Philippine Organic Act of 1902 (organic charter establishing civil government).
- Act of Congress of March 8, 1902, Section 9: conviction for treason requires testimony of two witnesses to the same overt act.
- Treason defined under U.S. federal law as levying war against the United States or adhering to its enemies.
Procedural History
De los Reyes was tried in the Court of First Instance of Manila for treason. He was convicted, sentenced to twenty years’ imprisonment and fined $5,000. He appealed to the Supreme Court of the Philippine Islands.
Facts
- A Constabulary detective detained de los Reyes in Bacord, Manila. He said a companion informed him that de los Reyes was a Katipunan captain. The defendant allegedly admitted his office in a private conversation.
- At de los Reyes’s home, officers seized a revolver and a sealed commission appointing him a captain in the “regular army” of the purported Philippine republic.
- The commission bore signatures of self-styled Katipunan officials, including “A. G. del Rosario, Supreme President” and “Cenon Nigdao, Minister of War.”
- The prosecution produced three witnesses:
- One explained the Katipunan as a secret organization aiming at independence by armed force and recounted an insurgent attack on U.S. troops.
- A second authenticated the seal on the commission and described the insurgent force as about 300 men.
- Cenon Nigdao identified his own signatures and described the group as seeking freedom from the U.S. government but admitted he commanded no troops and that no armed uprising occurred in Manila.
- A fourth witness, claiming a Katipunan commission, also testified that no actual army existed and that he surrendered voluntarily.
Issue
Whether the evidence—chiefly the issuance and possession of an insurgent army commission—satisfied the overt-act requirement for a treason conviction under applicable law.
Ruling
Conviction reversed; de los Reyes acquitted of treason.
Rationale
- Confession Exclusion: The alleged admission to the Constabulary was inadmissible because it was not made in open court as mandated by Section 9 of the March 8, 1902 Act.
- Contradictory Testimony: Witnesses variously described the organization as the Katipunan, the Tagalog Republic, or the National Party, and none proved de los Reyes actually levied war or carried arms in the field.
- Two-Witness Rule: The statute requires two witnesses to the same overt act of treason. Here, one witness testified to issuing the commission and another to its seizure—but no act beyond mere acceptance.
- Insuffici
Case Syllabus (G.R. No. 1434)
Procedural Posture
- The defendant, Antonio de los Reyes, was charged in the Court of First Instance of Manila with treason under Philippine Islands law.
- He was convicted and sentenced to twenty years’ imprisonment and a fine of $5,000.
- The case was brought before the Supreme Court of the Philippine Islands on appeal by the defendant.
Facts
- On or about August 30, 1902, the defendant accepted a commission as captain in the regular army of the so-called “Filipino republic,” an entity organized in opposition to U.S. authority.
- He allegedly served in that capacity and carried arms between August 30, 1902, and November 21, 1902.
- On November 21, 1902, a Constabulary detective and companion detained the defendant in Manila, questioned him in private, and obtained an admission that he was an officer of the Katipunan Society.
- A search of the defendant’s trunk at his home yielded a revolver and a sealed captain’s commission dated August 30, 1902.
Evidence Presented
- Constabulary detective testimony:
- Companion’s statement that the defendant was a captain in the Katipunan.
- Defendant’s out-of-court admission to being an officer.
- Discovery of a revolver and sealed commission in the defendant’s trunk.
- Exhibit A (Captain’s Commission):
- Issued by the self-styled “Supreme Presidency of the Philippine Islands.”
- Signed by Cenon Nigdao (Minister of War) and A. G. del Rosario (Supreme President).
- Testimony on the Katipunan/Tagalog republic:
- One witness characterized it as a secret organization aiming for independence by force.
- Another spoke of 300 armed men and recognized the seals on Exhibit A.
- Cenon Nigdao’s te